Finding 4: Policy for Indirect Costs and Monitoring of that Policy (2022- 04) 4.1 Action Plan To address the identified issues regarding the policy for indirect costs and monitoring of that policy, the organization will take the following steps: ? Formalization of Policy: Develop and formalize a policy to consistently charge a de minimis rate of 10% for indirect costs on all federal programs. This policy will replace the previous practice of determining indirect costs on a case-by-case or grant-by-grant basis. ? Documentation of Base Rate: Document the base rate for modi?ed total direct costs to establish a clear and consistent basis for calculating the 10% de minimis rate. ? Monitoring and Compliance: Implement procedures for monitoring compliance with the new policy, including regular reviews to ensure that the 10% rate is being applied consistently across all federal programs. 4.2 Responsible Personnel The newly hired Grants Manager, along with the executive management team, will be responsible for ensuring compliance with the new policy. Their responsibilities will include overseeing the implementation of the policy and monitoring its adherence across all relevant programs. 4.3 Resources and Tools Page 45 The organization will leverage its existing resources, including the custom-built grant management solution and QuickBooks Online, to facilitate the implementation and monitoring of the new policy. 4.4 Implementa3on Timeline The organization plans to implement the new policy immediately, applying the 10% de minimis rate to all new grants moving forward without delay. 4.5 Training and Support The organization will provide necessary training and support to the Grants Manager and other relevant personnel to ensure a smooth transition to the new policy protocols. This will include training on the calculation and application of the 10% de minimis rate. 4.6 Monitoring and Evalua3on A monitoring and evaluation mechanism will be established to assess the e?ectiveness of the new policy. This will involve regular reviews to ensure consistent application of the 10% rate and compliance with federal requirements, thereby preventing the charging of potentially unallowable costs to federal programs.